Privacy Policy

This Privacy Policy explains how NW MOON Education LLC ("NW MOON," "nwmoon", "we," "us") collects, uses, shares, and protects information when you use nwPal (the "App" or "Service") on iOS, Android, etc.

1) Minimum age

nwPal is intended for users 13 years of age or older. If you are under the age at which you can provide valid consent in your country (which may be 13–16 in Europe), then a parent/guardian must authorize consent for any nwPal features that rely on consent (for example, "use my chats for training"). If we learn that a user is under 13, we will take steps to delete the account and associated data.

2) What we collect

A) Information you provide

Account data

nwPal requires an account. We collect the identifier needed to create and manage your account (for example, email/Apple/Google sign-in identifier, depending on your login method).

Profile data (optional)

You may add optional information in Settings (e.g., name/username, profile photo, learning preferences). Profile photo is optional.

Chat content

We collect the text you type and the AI responses generated in nwPal. Your chat history may include multiple conversation threads. You can view and manage your chat history within the App, including deleting chats and/or deleting your account.

Support

If you contact Support, we collect the content of your request and information needed to respond.

B) Information collected automatically

We collect technical and usage data such as:

• App usage and interaction data
• Device and app information (device type, OS version, app version)
• IP address (stored/logged) (used for security, fraud/abuse prevention, and to infer coarse location such as country/region)
• Coarse location inferred from IP (country/region level)
• Analytics events and performance metrics
• Crash/diagnostic data (for stability and debugging)

C) What we do not collect (as of now)

• No voice/audio uploads
• No audio storage
• No user file/image uploads

3) How we use information

We use information to:

• Provide and operate nwPal (accounts, chat history, core learning features)
• Maintain security, prevent abuse, and enforce rules
• Improve reliability and performance (analytics, crash diagnostics)
• Provide customer support
• Send service communications (account notices, product updates)
• Send marketing communications if you opt in (where required by law)

Human review (NW MOON)

We may review chat content for safety and quality, including:

• Review of flagged chats (safety/abuse)
• Random sampling for quality improvement

We limit access to trained staff and apply internal controls.

4) Legal bases for processing (Europe)

Where European data protection law applies, we process personal data on the following bases, as applicable:

• Contract necessity (to provide and operate the Service you requested)
• Legitimate interests (such as securing the Service, preventing abuse/fraud, and improving reliability)
• Consent (for optional features such as training/improvement use of chats, where enabled)
• Legal obligations (where we must comply with applicable laws)

5) AI processing (OpenAI)

nwPal uses OpenAI to generate AI responses. To provide this, your chat text may be sent to OpenAI for processing.

6) "Training" use of your chats - consent required

We use your chat content for "training/improvement" only if you opt in.

A) NW MOON training/improvement (with your opt-in)

If you opt in, we may use your chat content to improve nwPal (for example, to evaluate quality, improve prompts, build safer filters, or train/improve NW MOON internal systems/models).

B) OpenAI data sharing for training (with your opt-in)

If you opt in, we may enable data-sharing mechanisms that allow OpenAI to use shared data to improve their models only where OpenAI offers an explicit opt-in path for such sharing.

Withdrawing consent

You can withdraw training consent at any time in the App (Settings → Privacy / AI Controls). Withdrawal applies going forward. Opting out of training/improvement does not affect your ability to use nwPal's core or paid features.

7) Advertising, cookies, and similar technologies

Advertising

nwPal may display NW MOON's own promotions (house ads). We do not display personalized third-party advertising based on your behavior.

Cookies and similar technologies

nwPal uses cookies and similar technologies (such as local storage and session storage) for essential and functional purposes, including to:

• keep you signed in and manage sessions
• remember preferences and settings
• enable core app functionality and performance
• maintain security and prevent fraud or abuse
• understand how the Service is used (analytics and diagnostics)

These technologies are necessary for the operation of a web-based application and PWA like nwPal and help ensure the Service works reliably and securely. We do not use cookies for third-party personalized advertising. Where required by applicable law, we will provide appropriate notices and choices regarding cookies and similar technologies.

8) Payments

nwPal is a paid service.

Current payment method (web)

At this time, paid access may be purchased through our website (nwmoon.com) using payment methods available at checkout.

Future payment methods

In the future, we may also offer additional payment methods (including platform billing or other processors). If we do, we do not store full payment card details. Depending on the payment method, we may receive transaction metadata needed to provide access and manage subscriptions (e.g., purchase status, product/plan identifier, renewal/expiration status, and timestamps).

9) Sharing of information

We may share information with:

• Service providers that help us operate nwPal (cloud hosting, analytics, crash reporting, customer support, AI processing such as OpenAI)
• Legal/safety recipients if required by law or to protect rights, safety, and security
• Business transfers (merger/acquisition/sale), where permitted

Third-party protection

We require our service providers and partners who process user data on our behalf to provide the same or equal protection of user data as described in this Privacy Policy and to process data only for authorized purposes.

10) Data retention and deletion

• Chat history: stored until you delete chats and/or delete your account, subject to this policy and applicable law.
• Account deletion: after you request deletion, we delete personal data within 30 days, unless we must keep limited records to comply with legal obligations.
• IP logs: retained for 90 days for security/diagnostics, then deleted or anonymized.

How to request deletion

You can initiate account deletion inside the App (Settings → Account → Delete Account). You can also contact privacy@nwmoon.com for help with deletion or data requests.

11) Your rights and controls

You can:

• Access and edit profile settings
• Export your data (available)
• Delete chats (available)
• Delete your account (available)
• Opt in/out of training consent at any time (where the feature exists)

If you are in Europe, you may also have rights to access, correct, delete, restrict processing, object, and data portability, and to lodge a complaint with a regulator.

12) International transfers

Our primary hosting is AWS in the EU (Frankfurt). However, some service providers (including AI, analytics, or crash reporting) may process data outside the EU depending on their infrastructure. Where required, we use appropriate safeguards for international transfers.

13) Security

We use reasonable technical and organizational measures to protect data. No system is perfectly secure.

14) Changes

We may update this policy and will update the "Last updated" date and publish the new version in-app and/or on nwmoon.com.

15) Contact

privacy@nwmoon.com

NW MOON Education LLC - Yerevan, Armenia